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The organization Friends of Oceano Dunes is determined to preserve the long history of off-road vehicle use on Pismo-Oceano beach. See the video below and the historic photos from Bob2000.com.

The Coastal Commission, which dislikes off-road vehicles as much as they dislike offshore oil and gas operations (well maybe not quite that much! 😉) lost a court case with some similarities to the suit filed by Sable Offshore.

Noozhawk: In an opinion filed Monday, the Second Circuit Court of Appeals found that the commission’s attempt to ban off-road vehicles at the Dunes contradicts the language of the Local Coastal Plan put in place by San Luis Obispo County.

The Court ruled that the decision to open or close the Dunes to vehicles fell under the jurisdiction of the county, not the Coastal Commission.

Sable’s dispute with the Commission is similar in that Sable contends that their pipeline repair and maintenance activities are in compliance with Santa Barbara County’s Coastal Zoning Ordinance, Local Coastal Program (LCP), and the Coastal Act. Will Sable also be victorious in Court?

Excerpt from the expedition summary:

The northeast coast of the United States is perhaps the best understood example of an offshore freshwater system, and multiple studies have been undertaken to determine the origin and volume of offshore freshwater. Coring and sampling the subseafloor offshore Massachusetts, USA, will provide data for understanding the processes driving emplacement of freshwater lenses offshore New England and elsewhere globally, and lead to a better understanding of this worldwide hydrogeological phenomenon. This is essential for protection and sustainable management of offshore freshwater systems and for better understanding biogeochemical and elemental cycling in continental shelf environments.

With regard to the potential freshwater resources (from the Nantucket Current):

“I’m just excited about the science, and that finally, after all these years, someone’s trying to get the truth,” said Nantucket Water Department director Mark Willett. “Computers predicted it. Everybody thinks it’s there. These guys are the first ones in the world who are going to go drill a hole and prove it.”

Willett and (lead scientist Brandon) Dugan are particularly intrigued by the possibility that the offshore freshwater aquifer could be connected to a lower, untapped aquifer beneath Nantucket that Willett calls “ancient glacier lake Nantucket.”

“If it is connected and it’s young water that’s being recharged actively today, that’s really exciting, because it’s a renewable source,” Dugan said.

The liftboat Robert will drill 3 wells to depths of 300-400 feet between May 1 and August 32.

In February, EPA Region 2 asked the agency’s Environmental Appeals Board to remand Atlantic Shores’ air emissions permit back to the Region for reconsideration. That remand (attached) was granted on 14 March over the objections of Atlantic Shores Offshore Wind.

Atlantic Shores Offshore Wind still exists despite the exit of 50% partner Shell and a $940 million write down by the remaining owner EDF. The diagram depicts Atlantic Shores South (0499) and North (0549) lease areas.

EDF intends “to preserve the company and its future development.” Whether or not they can hold the leases indefinitely without pursuing development remains to be seen. BOEM’s diligence regulations for offshore wind projects are vague, and neither the Construction and Operations Plans nor BOEM’s Record of Decision (Atlantic Shores South) include work schedules.

Does EDF have the right to sit on the lease until the financial and regulatory environment is attractive? That is not allowed for oil and gas leases, and rightfully so. (See a related post on Total’s wind lease.)

Meanwhile, ACK for Whales has petitioned EPA Region 1 to reopen and reanalyze the air permits for permits for the New England Wind 1 and 2 projects asserting that:

  • The analysis does account for emissions related to and resulting from blade failures, which would warrant emergency repairs or replacement activities.
  • The decision to group Vineyard Wind 1, New England Wind 1 and New England Wind 2, as a single stationary source is both legally questionable and could have the effect of masking localized emission spikes.
  • Insufficient consideration of cumulative vessel emissions could lead to 1-hour NO₂ exceedances.
  • The emissions from pile driving are not adequately modeled in isolation or synergistically.
WHOI graphic: The AMOC not only distributes the ocean’s heat, moisture, and nutrients, but regulates the Earth’s climate and weather.

Contrary to alarmist forecasts that climate change could cause the Atlantic Meridional Overturning Circulation (AMOC) to collapse as soon as 2025, an important Woods Hole study found that the AMOC has not declined in the last 60 years.

“Based on the results, the AMOC is more stable than we thought,” co-author Linus Vogt said. “This might mean that the AMOC isn’t as close to a tipping point as previously suggested.”

Of course, the usual caveat about past performance not necessarily being predictive applies:

Co-author Nicholas Foukal: “That doesn’t say anything about its future, but it doesn’t appear the anticipated changes have occurred yet.”

Perhaps the urgent warnings about the collapse of the AMOC, if not unfounded, were at least premature.

Attached is a recent Sable Offshore presentation for investors. Notably, Sable is now projecting to resume Santa Ynez Unit production in Q2 2025 (see slide below). John Smith thinks this is unrealistic, and I have to agree.

It’s tough for an offshore producer to succeed in California, but Sable is making a strong effort. Exxon must agree, because they have extended Sable’s first production deadline to 3/1/2026, which reflects a more plausible Q1 2026 restart. Additional extensions seem likely if necessary given that Exxon’s other options aren’t very attractive.

BOEM’s 2024 Marine Archaeology Rule

Exercising authority granted in the Congressional Review Act (Chapter 8 of Title 5 of the United States Code), Congress passed Joint Resolution 11 nullifying the Bureau of Ocean Energy Management rule titled “Protection of Marine Archaeological Resources” (Sept. 3, 2024).

Nullification of a final rule is not common. Since its Enactment in 1996, the CRA has been used to overturn only 20 rules. This is the first time an OCS energy rule has been nullified.

Enactment of a CRA resolution of disapproval is unlikely in most circumstances, because a President would be expected to veto a joint resolution disapproving a rule issued by the President’s own Administration.

There are also time limitations for nullifying a rule. The joint resolution must be introduced during a 60-days- of-continuous-session period beginning when the rule has been published in the Federal Register and been received by Congress. However, if within 60 session days after a rule is submitted, Congress adjourns its session, the periods to introduce and act on a disapproval resolution reoccur in their entirety in the next session of Congress.

It’s also noteworthy that a CRA resolution cannot be filibustered if the Senate acts on the resolution during a 60-days-of-Senate-session period beginning when the rule has been received by Congress.

Most of the 20 nullifications involved rules finalized at the end of a previous administration that were nullified at the beginning of a new administration with a majority in both chambers of Congress. That is the case for the Marine Archaeology Rule, which was published at the end of the Biden administration and nullified at the beginning of the Trump administration. .

The nullified OCS rule required operators to submit an archaeological report identifying potential archaeological resources with any exploration or development plan. The rule modified regulations that only required such a report only when a BOEM regional director had reason to believe that an archaeological resource may be present in the lease area. 

Archaeological survey requirements have been somewhat contentious since they were introduced in the 1970s. There were concerns about decisions to require the protection of speculative, low probability sites that could significantly alter operating plans.

A reasonable balance and an apparent consensus was achieved by limiting the report requirements to areas where studies and other information indicated the potential for such resources. BOEM’s new rule tightened the requirement considerably, which led to opposition and ultimately nullification.

Resolution Timeline

2/4/2025SenateResolution Introduced by Sen. Kennedy
2/25/2025SenatePassed by Yea-Nay Vote 54 – 44
3/6/2025HousePassed by Yea-Nay vote: 221 – 202, 1 Present
3/13/2025Presidentsigned

Juergen Maier, chairman of GB Energy, “a planned British government-owned renewable energy investment body,” is promising to revive Aberdeen with “green energy” jobs, and to create “something special for the years ahead.”

Maier: “Floating offshore wind, green hydrogen, and carbon capture should be as synonymous with Aberdeen’s future as oil and gas have been with its past.” This is an interesting comment given that the success of the industries he is promoting is far from assured; nor is the continuation of government edicts and subsidies on which they are dependent.

How many times have we been told that the government driven energy transition would create thousands of jobs? How many workers in economically important industries have been told to transition to politically favored professions? How many Keystone Pipeline workers found the promised “green energy jobs?” Why were coal miners condescendingly told to “learn to code?”

Perhaps Mr. Maier should broaden his message by showing support for development of the Rosebank and Jackdaw fields, and for sustaining production of oil and gas, on which the UK will be dependent for many years. As Louise Gilmour wisely opined in her column in the Scotsman:

We need more of it because even the most ardent supporters of renewable energy, the most vocal proponents of net zero, quietly admit oil and, especially, gas will be needed for a couple of decades at least. That obvious truth, that inarguable necessity, is not, apparently, enough for ministers to encourage UK production, however, or temper their rhetoric around renewables.

Allowing our rigs and refineries to power down and relying on other countries to keep the lights on still seems a little, well, counter-intuitive. We will import oil and gas but not produce it while happily exporting contracts, skills and jobs overseas? The practical impact of Labour’s refusal to grant new exploration licences in the North Sea might remain unclear but the message it sent was absolutely crystal.

China plans to build an “Offshore Space Station” 2,000 meters below the ocean surface in the South China Sea. The plan is to complete the station, which will accommodate 6 scientists, by 2030.

This is by far the deepest water for which a subsea human habitat has been proposed. By comparison, the planned Proteus (Fabien Cousteau) underwater station will be in just 20 meters of water off the northeast coast of Curaçao. A Sentinel/UK habitat is planned for depths up to 200 meters in the Mediterranean.

The primary focus of the deepwater South China Sea facility will reportedly be the study of deepwater seep ecosystems which are rich in marine life and deposits of methane hydrates. Hydrates are an energy resource that has much potential. However, because of the risk of uncontrolled methane releases and seafloor instability, there is limited support for the production of hydrate methane.

A deepwater science station near hydrates and methane seeps would be a dangerous operating environment given the potential for methane blowouts and cratering caused by destabilized hydrates. Given that nearly all of the research could be conducted safer and cheaper with Autonomous Underwater Vehichles (AUVs) and advanced robotics, the scientific value of a deepwater station seems questionable.

The offshore oil and gas industry considered subsea habitats in the 1970s but has since abandoned the idea. Lockheed designed a one atmosphere seafloor chamber (diagram below) that was installed in the Gulf in 1972 at a water depth of 375 ft.

Dry chamber well and production systems lost favor because of concerns about flooding, high costs, and safety risks associated with transporting workers to the chambers and placing them in close proximity to “live” wells and production equipment.

Perhaps the main drivers for China’s deepwater “space station” are geopolitical. Taiwan, Vietnam, the Philippines, Malaysia, and Brunei reject Beijing’s claims of sovereignty and each claim parts of the South China Sea (see map below).

By establishing a seafloor community in a strategic location, China could strengthen its highly questionable claim to the entire South China Sea. China would also have reason to increase Navy vessel activity in disputed waters to support and defend their subsea community.

This will be a project to watch if it actually goes forward.

Santa Barbara resident Julia-Louis Dreyfus fires up the crowd. Photo Credit: Ingrid Bostrom, Independent

The Santa Barbara Independent and Noozhawk have closely followed the Sable saga and provided good coverage of the “Information Meeting.” BOE contributor John Smith followed the meeting online and shares his impressions.

Independent: “What was advertised as an informational meeting with eight state agencies that oversee Sable’s operations quickly became emotionally charged when the Environmental Defense Center’s Linda Krop and resident actor Julia Louis-Dreyfus were surprisingly called onto the stage to voice their opposition to the oil project.

John Smith reports that the meeting got off to a good start before deteriorating:

Smith: “The CCC (Coastal Commission) presentation was interesting because it highlights their position and disagreement with SBC (Santa Barbara County) who determined permits were not required by Sable for maintenance and repair work.  I think the agencies did a good job in sharing information on the status of permits, which if people were objective, may have alleviated many of their major concerns.  Unfortunately, it went downhill at the end when EDC and Hollywood types were given the floor.”  

Unsurprisingly, a State Senator facilitated the ambush:

Independent: “When Senator Limón’s staff called to the stage the Environmental Defense Center’s chief counsel, Linda Krop — who hosted a star-studded press conference beforehand with state legislators, actors Julia Louis-Dreyfus and Jane Fonda, and Ventura-based Patagonia CEO Ryan Gellert, among others, outside the EDC’s headquarters — the town hall shifted gears from an info-session into a quasi-rally. Krop’s emotion-inciting words, followed by an angry, passionate speech from Louis-Dreyfus, put the room into a cacophony of cheers and jeers.

Sable supporters (workers, not movie stars) were also in the house:

Independent: “Sable Offshore management, employees, contractors, labor, and supporters showed up today in good faith to participate in a town hall meeting where only government officials were on the agenda to present,” said Steve Rusch, Sable’s vice president of environmental and governmental affairs, in a statement. “Project opponents forced the moderators to give them dedicated time to present biased information and smear the project. The opponents’ self-serving fundraiser and rally was not an appropriate use of public resources.”

Not one word was said about the working people,” a Sable employee and union member told the Independent after he walked out. “This is my home, too, and I’m going to fight, too…. Without this, we’re just unemployed.”

Interestingly, regulatory fragmentation, a topic that this blog has railed about, was mentioned by one of the Sable opponents, and I suspect the Sable supporters agree!:

Noozhawk: “One of the audience members was Ravid Raphael, who has lived in Goleta for the past 11 years. One of his concerns was that there are too many departments and that they are too fragmented.

Jane Fonda (no one would question her credibility😉) – Photo Credit: Ingrid Bostrom, Independent

See the attached letter from Sable’s attorneys; highlights below:

  • The Commission staff appears to be asserting Commission jurisdiction over already permitted activities in order to attempt to exert influence over Sable’s planned restart of the Santa Ynez Unit oil production operations. Jurisdiction over restart activities is entirely outside of the Commission’s jurisdiction and is separately regulated by other agencies.
  • Sable’s repair and maintenance activities (anomaly repairs, safety valve installation, and span remediation) are in compliance with applicable provisions of Santa Barbara County’s Coastal Zoning Ordinance (CZO), certified Local Coastal Program (LCP), and the Coastal Act. As such, no cease and desist order is warranted – whether issued by the Executive Director or the full Coastal Commission.
  • The onshore and offshore repair and maintenance work is fully authorized by coastal development permits previously approved by Santa Barbara County and the Commission. Therefore, those activities do not require new or amended coastal development permits and are not otherwise subject to the Commission’s jurisdiction or enforcement authority.
  • Onshore anomalies: Santa Barbara County reviewed the detailed information Sable submitted with Zoning Clearance applications in 2024 and confirmed in a letter dated February 12, 2025, that the anomaly repair work is authorized by the pipelines’ existing coastal development permits and, consistent with past practice, no new or separate Coastal Act authorization is required for Sable to perform the work. Commission staff has repeatedly ignored that the County — as the applicable agency with delegated LCP authority under the Coastal Act — expressly has confirmed that the anomaly repair work was authorized by the onshore pipelines’ existing Coastal Development Permit, Final Development Plan, and Conditions of Approval.
  • Onshore safety valves: Sable was required to undertake safety valve repair and maintenance activities pursuant to state law that the Coastal Commission supported. The safety valve repair work involves the exact same type of work as pipeline anomaly repairs, and Sable completed the safety valve work only after the County confirmed in writing that no further authorization from the County was required for the safety valves.
  • Offshore span remediation: Sable’s span remediation maintenance activities were fully contemplated and authorized within the original coastal development permit approved by the Coastal Commission for the Offshore Pipelines in 1988 and the Development and Production Plan approved by the Department of the Interior. The span remediation maintenance activities involve the placement of sand-cement bags beneath certain segments of the offshore pipelines to provide additional pipeline support. The exact same support enhancement (span remediation) activities have been performed in the past on these same offshore pipelines without requiring any new Coastal Act authorizations.
  • Sable has filed a lawsuit against the Commission in Superior Court in Santa Barbara County where it has asked the Court for damages and declaratory and injunctive relief to protect its vested rights to repair, maintain and operate the Santa Ynez Unit and Las Flores Pipeline Systems.